This policy together with our Terms and Conditions applies to your use of the TDL TestGuide mobile application (the “Service”). This policy explains what personal data we will collect when you use the Service and how we will use that personal data.
Important information and who we are
The Doctors Laboratory Limited is the controller and is responsible for your personal data (collectively referred to as, "we", "us" or "our" in this policy).
Our full name and address is:
The Doctors Laboratory Limited
The Halo Building, 1 Mabledon Place
London WC1H 9AX
You can contact us by writing to the DPO at our postal address above, or by email to: firstname.lastname@example.org.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues or other competent supervisory authority of an EU member state if you download the TDL TestGuide application outside the UK.
This version was last updated on 12 December 2019. It may change and if it does, these changes will be posted on this page. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Service.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
Third party links
Our Service may, from time to time, contain links to and from the websites of third parties. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.
The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Account Data: means your name, your email address, your profession, your username and password, and the name of the organisation that provided you with the code you used to set up your account with the Service, and any correspondence between you and us.
- Usage Data: means details of your use of any the Service and information provided to us automatically by the device you use to access the Service. Usage Data includes, but is not limited to, your Internet Protocol address, browser type, browser version, the pages of the Service that you visit, the time and date of your visit, the time spent on each page you visit, unique identifiers of the device you use, the type of device you use, your device operating system, and other diagnostic data.
- Location Data: means information about your location.
How is your personal data collected?
We will collect and process the following data about you:
- Information you give us. This is information that you give us by filling in forms in the Service (for example when you create your account), by setting preferences in the Service (for example, by saving a page to your favourites), or by corresponding with us (for example, by email or chat).
- Information we collect about you and your device. Each time you use the Service we automatically collect Usage Data. We collect this data using cookies and other similar technologies.
- Location Data. We also use GPS technology or other technology to determine your current location if you decide to enable Location Data. Some of our location-enabled Service require this data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your device settings.
How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing.
- Where we need to perform a contract we are about to enter or have entered with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Purposes for which we will use your personal data
|Purpose/activity||Type of data||Lawful basis for processing|
|To install the Service and register you as a new Service user||Account Data
|To provide customer support to you||Account Data
|Necessary for our legitimate interests (to resolve support queries you raise with us)|
|To analyse how people use the Service and develop improvements to the Service and new services||Account Data
|Necessary for our legitimate interests (to improve the Service and develop new services)|
|To administer and protect our business and Service, including to detect, prevent, and resolve technical
issues with the Service
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)|
|To manage our relationship with you including notifying
you of changes to the Service and exercising our rights
under the Terms and Conditions.
|Necessary for our legitimate interests (to respond to correspondence from you and exercise our rights under the Terms and Conditions)
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
|To comply with our legal obligations, including
obligations regarding the retention and disclosure of data.
|All data||Necessary for us to comply with a legal or regulatory obligation|
Disclosures of your personal data
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table above:
- Other businesses in the TDL group of business who assist us to provide the Service or to carry out any of the purposes explained in this policy.
- Service providers acting as processors who provide IT services, analytics services and system administration services to us.
- Professional advisers who need the data in order to provide advice to us, for example legal advisors.
- Mixpanel, which is GDPR-compliant software that we use for analytics. It is part of the data collected when a user puts in a request of 'Send me a copy of my data'.
- Any third party that the law requires us to disclose the data to, or where we believe (acting in good faith) that the law requires us to disclose the data.
Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us at using the contact details at the start of this policy.
Your legal rights
You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- (a) if you want us to establish the data's accuracy;
- (b) where our use of the data is unlawful but you do not want us to erase it;
- (c) where you need us to hold the data even if we no longer require it as you need it to establish,
exercise or defend legal claims; or
- (d) you have objected to our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.